Most organisations discover their F-Gas obligations at the worst possible moment: when a decommissioning contractor asks who is recovering the refrigerant, three days before the cooling plant is due to come out.
This checklist is written for the operator of the equipment rather than the engineer who services it. That distinction matters, because the legal duties sit with the operator and cannot be contracted away, only delegated.
It also corrects something worth knowing. A considerable volume of commentary published this year describes changes to the Great Britain regime that have not taken effect. Defra consulted on reforming the GB phase-down schedule in late 2025, and on 15 May 2026 confirmed that it would not introduce legislation during 2026 to change the steps due from 1 January 2027. The existing 2027 step stands, and a formal response was expected later in the year.
Several figures that circulate widely relate to the EU regime only and do not apply in Great Britain: a charge per tonne of CO2 equivalent on quota, an end date for reclaimed refrigerant use, and equipment bans from 2027. Supply pressure and price are genuinely tightening, and a further quota step does apply from January 2027, so planning is justified. But if a supplier is justifying urgency by citing a GB rule change during 2026, it is worth asking which instrument, and worth looking harder at the rest of the proposal.
The threshold catches more equipment than people expect, because scope is determined by carbon dioxide equivalent rather than by weight of gas. Five tonnes CO2 equivalent is 0.3 kg of HFC 23, 1.3 kg of HFC 404A, or 2.4 kg of HFC 410A. Under a couple of kilogrammes is enough to be in scope, which captures effectively every commercial system above a small wall mounted split.
Two categories are missed almost universally. Gaseous fire suppression is not refrigeration, so it never gets inspected alongside the cooling plant and frequently sits outside the facilities register entirely, which means a data hall often carries obligations in both its cooling and its suppression. And heat pumps, usually installed recently under a different contract, rarely make it onto an existing register.
There is a section on the three regimes operating across these islands. Great Britain runs its own framework which has diverged from the EU regulation. Northern Ireland follows the EU regime, as does Ireland. A single group policy written to the GB position will understate obligations at Northern Ireland sites.
The end of life section is the reason an IT asset disposition company publishes this. Refrigerant must be recovered by a certified party before equipment is cut, moved for scrap or dismantled, and that applies whether the plant is being scrapped, sold or relocated, and whether it has been out of service for years. Venting is a criminal matter and among the very few things in a decommissioning project that can attract personal as well as corporate consequences. A contractor who suggests simply cutting the pipes is a liability rather than a saving.
The recovery record in the appendix includes a discrepancy field, which is the uncomfortable and correct one. If the nameplate charge was 40 kilogrammes and 28 were recovered, the difference went somewhere, and the likely explanation is a historic leak that was never recorded. It is also the last opportunity to identify a record keeping failure while anything can still be done about it.
Inside the 27 pages: what is in scope and how to calculate it, the 2026 position, who legally counts as the operator, leak check intervals by CO2 equivalent bracket, the GB and EU divergence, record keeping and the eight failures that show up on inspection, certification and what to actually check, end of life recovery, and a set of questions for your service provider.
Five appendices: an equipment register, a leak check log with a leak repair and follow-up section, a recovery record, a 24-point compliance checklist and a glossary.
NanoSoft does not hold F-Gas certification and does not perform refrigerant recovery. This checklist exists because refrigerant recovery is a hard gate in any facility or data centre decommission, and it is the gate most often discovered late.
Free, customisable. Everything in square brackets is a field you complete.